enforced disappearance; 331 in other words, any form of deprivation of liberty meets this first requirement. On this point, the United Nations Working Group on Enforced or Involuntary Disappearances has clarified that “the enforced disappearance may be initiated by an illegal detention or by an initially legal arrest or detention. That is to say, the protection of the victim from enforced disappearance must be effective upon the act of deprivation of liberty, whatever form such deprivation of liberty takes, and not be limited to cases of illegitimate deprivations of liberty.” 332 The Court finds that the fact that the victims exited the Palace of Justice alive, in the custody of State agents, satisfies this first element of the deprivation of liberty in an enforced disappearance. 233. The Court also notes that there is no impediment to the use of indicative evidence to prove the concurrence of any of the elements of forced disappearance, including the deprivation of liberty. In this regard, it is pertinent to refer to the case of González Medina and family members v. Dominican Republic, in which the Court, using indicative evidence, concluded that the victim had been detained and, subsequently, forcibly disappeared. 333 Also, in the case of Osorio Rivera and family members v. Peru, the Court decided that what happened to the victim constituted a forced disappearance and, to this end, it was necessary to infer that his detention had continued following an order to release him. 334 This opinion is shared by the European Court of Human Rights which has indicated that, in cases in which the detention of an individual by State authorities has not been proved, this detention may be presumed or inferred if it is established that the individual entered a place under the control of the State and has not been seen since. 335 331 The 1992 Declaration on the Protection of All Persons from Enforced Disappearance establishes that enforced disappearances occur when: “persons are arrested, detained or abducted against their will or otherwise deprived of their liberty by officials of different branches or levels of Government, or by organized groups or private individuals acting on behalf of, or with the support, direct or indirect, consent or acquiescence of the Government, followed by a refusal to disclose the fate or whereabouts of the persons concerned or a refusal to acknowledge the deprivation of their liberty, which places such persons outside the protection of the law.” In addition, Article 2 of the 2006 International Convention for the Protection of All Persons from Enforced Disappearance defines enforced disappearance as: “the arrest, detention, abduction or any other form of deprivation of liberty by agents of the State or by persons or groups of persons acting with the authorization, support or acquiescence of the State, followed by a refusal to acknowledge the deprivation of liberty or by concealment of the fate or whereabouts of the disappeared person, which place such a person outside the protection of the law.” Meanwhile, Article II of the Inter-American Convention on Forced Disappearance defines forced disappearance as: “the act of depriving a person or persons of his or their freedom, in whatever way, perpetrated by agents of the State or by persons or groups of persons acting with the authorization, support, or acquiescence of the State, followed by an absence of information or a refusal to acknowledge that deprivation of freedom or to give information on the whereabouts of that person, thereby impeding his or her recourse to the applicable legal remedies and procedural guarantees.” 332 Working Group on Enforced or Involuntary Disappearances, Report of the Working Group on Enforced or Involuntary Disappearances, General comment on the definition of enforced disappearances, A/HRC/7/2, 10 January 2008, para. 7. See also, Case of Blanco Romero et al. v. Venezuela. Merits, reparations and costs. Judgment of November 28, 2005. Series C No. 138, para. 105, and Case of Osorio Rivera and family members v. Peru. Preliminary objections, merits, reparations and costs. Judgment of November 26, 2013. Series C No. 274, para. 125. 333 Cf. Case of González Medina and family members v. Dominican Republic. Preliminary objections, merits, reparations and costs. Judgment of February 27, 2012. Series C No. 240. 334 Cf. Case of Osorio Rivera and family members v. Peru. Preliminary objections, merits, reparations and costs. Judgment of November 26, 2013. Series C No. 274. 335 The European Court indicated: “Where the events in issue lie wholly, or in large part, within the exclusive knowledge of the authorities, such as in cases where persons are under their control in custody, strong presumptions of fact will arise in respect of injuries and death occurring during that detention. Indeed, the burden of proof may be regarded as resting on the authorities to provide a satisfactory and convincing explanation […].These principles apply also to cases in which, although it has not been proved that a person has been taken into custody by the authorities, it is possible to establish that he or she entered a place under their control and has not been seen since. In such circumstances, the onus is on the Government to provide a plausible explanation of what happened on the premises and to show that the person concerned was not detained by the authorities, but left the premises without subsequently being deprived of his or her liberty.” European Court of Human Rights (ECHR), Case of Khadzhialiyev 78